5.01 The purpose of the monitoring process is to proactively review whether the policies of the LDP are being implemented and the plan strategy is being delivered. There is a need to review the level of population and household growth that the LDP will provide for within the revised plan period. The level of growth that is planned for needs to be reconsidered in order to ensure that sufficient development and in particular housing and economic development is provided to meet the anticipated need of the population over the revised plan period.
5.02 Therefore, CCBC will undertake a review of all LDP policies based on the findings of previous annual monitoring reports and evidence of any significant contextual changes, such as changes in the local context and/or changes to national policy or legislation. A summary of whether a policy is functioning effectively and whether changes are necessary as part of the plan revision is provided in Appendix 3. Policies that are significantly affected by contextual changes and are likely to require modification are discussed in more detail below under their relevant topic headings.
5.1.1 The Development Principles chapter of the LDP sets out a number of policies against which all developments must adhere to. This includes strategic policies relating to the overall spatial strategy, which are likely to change as part of the LDP Review. Changes to these policies will need to reflect the latest evidence available at the time of Examination of the replacement LDP. Policy DP/2 sets out the overall spatial distribution of development, hierarchy of settlements and affordable housing requirements. Further detail in relation to these issues are set out in Chapter 4 and the Housing section of this Review Report.
5.1.2 Policies DP/3 and DP/4 provide a number of development management criteria against which proposals are assessed. These cover a wide range of issues including design, access, biodiversity, safety and flood risk. Whilst the overall aims of these policies are unlikely to change significantly, as part of the Review there may be some amendments required as priorities for development change or new arise issues that need to be considered.
(4) 5.1.3 The preparation of a CIL charging schedule in Conwy is in progress but pending a national review of CIL in Wales. Policy DP/5 may need amending to reflect that some infrastructure may be delivered via CIL in future. Site specific infrastructure requirements will continue to be secured via current mechanisms.
5.1.4 Since adoption of the LDP, support for Place Plans has gained momentum at a National level through the Planning Act and changes to the LDP Manual. A pioneering Place Plan in Abergele is moving forward under the emerging national framework. Policy DP/7 will need to be reviewed to ensure that the policy and any future Place Plans align with the new national guidance.
5.1.5 The Colwyn Bay Masterplan was originally produced in 2009/10 and formed the culmination of a consultancy commission led by DPP Shape, working with Arc 4, Keppie Massie and Martin Stockley Associates. Throughout the process of creating a Masterplan, the challenge has been to re-invent Colwyn Bay as a 21st century town with a renewed focus on its role as a seaside town and an attractive place to live, visit and invest. Since the start of the project the Bay Life programme has successfully completed a number of projects in Colwyn Bay and other significant projects are currently ongoing.
5.1.6 In 2014 at the request of the Council, Nathaniel Lichfield and Partners (NLP) undertook a review of the draft Masterplan SPG in terms of correlation with both local and national planning policy. The outcome from this exercise was a series of recommendations on how the supplementary planning guidance to support LDP policy DP/8 should be revised to reflect such policy linkages. At a similar time it was considered that the town centre options for the Masterplan should be reconsidered to ensure feasibility and reflect a number of significant developments and changes that have occurred since the Masterplan was first compiled.
5.1.7 To summarise, the work on the town centre review of the Masterplan is currently ongoing and the outcomes of this are likely to lead to a review of policy DP/8, with possible implications for review of the LDP proposals map in terms of designations / allocations in Colwyn Bay town centre.
(5) 5.2.1 The LDP Strategy seeks to deliver approximately 6,520 new dwellings inclusive of completions, commitments, windfall and new allocations over the Plan period. This target equates to a build rate of 435 new dwellings per annum which is extremely ambitious compared to the past build rates in Conwy shown in the graph below.
(4) 5.2.2 The 2017 Joint Housing Land Availability Study (JHLAS) indicates that 3114 dwellings have been delivered. Whilst this represents a large number of dwellings, the level is significantly below the LDP requirements. There is little doubt that the economic downturn has had a significant effect on the delivery of dwellings over recent years.
5.2.3 Planning Policy Wales 9th Edition (2016) is clear in that local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5 year supply of land for housing (paragraph 9.2.3). CCBC has not achieved a 5 year land supply since 2009/10 and the most recent JHLAS has calculated a 3.1 year housing land supply in 2017 (Table 5.1).
(3) 5.2.4 Technical Advice Note (TAN) 1: Joint Housing Land Availability Studies (January 2015) states that where the local planning authority has a shortfall in housing land supply, consideration should be given to the reasons for the shortfall. As indicated above, the economic downturn has had a significant effect on the delivery of housing allocations and this is considered to be principal reason for not achieving a 5 year land supply since 2009/10. Notwithstanding this, there remains a need to review all undeveloped housing allocations in the LDP to ensure that development on these sites remains viable and the allocations will be delivered. This could result in certain housing allocations being removed from the LDP and new sites being allocated to meet local housing needs up to 2031. A formal 'call for candidate sites' inviting anyone to put forward potential sites for development will form part of this process. In order to accommodate changes that are required to allocations, settlement boundaries will be revised where necessary.
(4) 5.2.5 It is important to note that where the housing land supply figure is below the 5 year requirement, TAN1 6.2 states that the need to increase supply should be given considerable weight when dealing with planning applications for housing, provided that the development would otherwise comply with the development plan and national policies. Given that CCBC only has a 3.1 year housing land supply, considerable weight would have to be given to any speculative housing development that meets the aforementioned criteria, as was the case in the recent appeal decision for residential development at Sychnant Pass, Conwy (planning ref 0/41960). This situation, therefore, has the potential to undermine the plan-led approach which provides certainty for developers and the public about the type of development that will be permitted at a particular location.
Total LDP requirement (1/4/2007 - 31/3/2022)
Completions 1/4/2007 - 31/3/2017
Empty Homes Delivery 1/4/2007 - 31/3/2017
Total Completions 1/4/2007 - 31/3/2017 (B + C)
Residual Requirement (A - D)
Years Remaining of LDP
Residual Annual Requirement (E / F)
JHLAS Sites (including Contingency Sites)
Small sites contribution
Empty Homes contribution
Total 5 Year Land Supply (H + I + J)
Land Supply in Years (K / G)
5.2.6 A shortage of Affordable Housing for Local Need (AHLN) is one of the most pressing priority issues for Conwy and many other Local Authorities in Wales. WG Technical Advice Note (TAN) 2: 'Planning & Affordable Housing' requires local authorities to include an affordable housing target in their development plans and indicate how this target will be achieved using identified policy approaches. Local Housing Market Assessments (LHMA) provide the evidence base for policies to deliver both market and affordable housing.
5.2.7 In line with the findings of the Affordable Housing Viability Study and Conwy's priority objectives to contribute to affordable housing delivery, Policy HOU/2 seeks a viable contribution from all housing developments of varying percentages within the Urban Development Strategy Area and Tier 1 Main Villages. Within the Tier 2 Main Villages, Minor Villages and Hamlets, development should only take place to meet evidenced local need for affordable housing. In some circumstances, subject to viability, market housing may be permitted where necessary to bring forward the affordable housing development.
(5) 5.2.8 Actual delivery of affordable housing on most sites has been below the levels required by policy HOU/2. This has been for several reasons, with circumstances differing on individual sites. To address this, the policy will need to be reviewed through further viability testing, whilst the call for sites will include more rigorous assessment of viability at an early stage to reduce the possibility of planning obligations being reduced due to high land values or abnormal costs. In addition, the approach to the affordable housing requirements for conversions will need to be reviewed; particularly in the open countryside where an appeal decision has identified a gap in LDP policy relating to the lack of a specific AH requirement.
(4) 5.2.9 A total of 277 affordable housing units have been delivered through the planning system since the LDP was adopted in 2013. It should be noted that CCBC also delivers affordable housing through other mechanisms including through grant funding, bringing empty homes back into use and work with housing partners, RSLs, etc.
5.2.10 It is anticipated that the recently adopted Affordable Housing SPG will assist in the delivery of AH and provides necessary guidance around the following areas:
- Defining Affordable Housing & Affordability
- Housing Need
- Affordable Housing Provision
- Exception Sites
- Rural Enterprise Dwellings (REDs)
- Housing Density & Mix
- Viability and Delivery
(4) 5.2.11 The latest LHMA (2016-2021) shows a total annual affordable housing need of 199 dwellings compared to an annual requirement of 123 dwellings identified in the 2013 LHMA. However, t he final level of Affordable Housing will be subject to the LDP Review process having considered the new population/household projections, growth strategy options and related evidence.
Houses in Multiple Occupation
5.2.12 Policy HOU/10 - 'Houses in Multiple Occupation and Self Contained Flats' states that all proposals to create Houses in Multiple Occupation (HMOs) will be resisted. This stance was based on historic problems in Conwy, particularly in Colwyn Bay, where HMOs often provided a relatively poor living environment and rarely made a positive contribution towards the housing quality of an area.
5.2.13 The type of building that can be described as a HMO has broadened since the policy was adopted. It now includes blocks of self-contained flats and converted houses. Since March 2017, new requirements for property owners to seek permission for a change of use from 'dwelling house' to 'small HMO' (where they are let to 3-5 unrelated persons), extends the scope of the policy application to shared housing arrangements. These changes could not have been foreseen when the policy was adopted.
5.2.14 Since the adoption of the Policy, significant changes to the regulation of private sector rented accommodation have come into force allowing for the poor physical property standards, social and environmental issues, to be addressed directly.
CCBC Local Housing Market Assessment (LHMA) 2016-2021 says
'HMOs cover a wide range of housing types mainly in the private rented sector, including bedsits and other types of accommodation with shared facilities. They are often occupied by single persons with lower incomes and can include some vulnerable and disadvantaged groups. Well managed and maintained HMOs are an important tenure choice for households on low incomes, in particular single persons under the age of 35 who typically are only eligible for housing benefit at the shared accommodation rate.'
5.2.16 Welsh Government is expecting social housing providers to develop shared housing and Conwy has set up a shared housing working group to develop opportunities within the Borough. The young person positive pathway work being undertaken between Housing and Social Care has underlined the need for affordable shared housing. The existing policy restricts the development of affordable, social shared and supported housing schemes and limits the Council's ability to respond to social, environmental and strategic housing priorities.
5.2.17 In view of the identified need, the impact of Welfare Reform, Local Housing Allowance levels, changes in guidance and recent appeal decisions, it is considered that a further assessment of HOU/10 is required as part of the LDP Review process.
Gypsy & Traveller Sites
(1) 5.2.18 Policy HOU/9: 'Meeting the site need for Gypsies & Travellers' of the existing LDP was informed by the 2013 Gypsy & Traveller Accommodation Needs Assessment (GTANA) which identified a need for 3 residential pitches in Conwy by 2016 (projected to grow by 3% per annum) and a transit site for up to 7 caravans on the County border with Denbighshire County Council, where the two authorities may be able to co-operate in provision in order to maximise usage.
5.2.19 CCBC have now developed a 4 pitch residential site on the outskirts of Conwy town with the aid of WG grant funding and four families are now occupying the site.
5.2.20 The latest GTANA (January 2017) indicates a need for one additional residential pitch and the same transit need as the previous GTANA (7 pitches).
5.2.21 In relation to the additional residential pitch, it should be noted that it will be challenging to provide a further pitch at the Conwy town site due to a lack of available land. CCBC and WG also acknowledge that a one pitch site may not represent value for money.
5.2.22 Police have separate powers under the Public Order Act 1994 to direct both trespassers and Travellers to leave land and remove any vehicle and property from the land where there is a suitable pitch available on a caravan site elsewhere in the local authority area. Therefore, if a transit site was provided in Denbighshire only, unauthorised encampments within Conwy County could not be moved onto it. In view of this it was considered that a joint transit site would be inadequate.
5.2.23 CCBC have now begun the 'call for sites' process for finding and developing a suitable transit site with the aid of WG grant funding. Subject to further agreement by Cabinet, the preferred location for a transit site will then be progressed via a formal planning application and/or the formal LDP Review process.
5.3 The issues:
Poor take-up of employment land
(3) 5.3.1 LDP Policies EMP/1 & EMP/2 identify a need for a total of 39.5 hectares of B1, B2 & B8 office and industrial employment land (including completions, committed sites, allocations and contingencies) over the Plan period in the Urban Development Strategy Area and the Rural Development Strategy Area.
(1) 5.3.2 There are a number of concerns emerging relating to the implementation of the Economic Strategy, some of these are relating to the take-up of employment land in terms of new permissions and completions. The performance against indicators within the AMR appear to be showing a lack of demand for new employment (B class) land uptake in Conwy, and whilst the general economic climate could be a prevailing factor, it may also be an indication that the amount, location and supply of employment land is not matched to demand. It has also been noted that a number of applications are being made for use of allocated and safeguarded B1, B2 and B8 sites for other uses such as health facilities, schools and gymnasiums rather than B class uses. Further examination of economic activity since adoption of the LDP is analysed further below:
5.3.3 Monitoring indicator MI/026 measures development of employment land within the Urban Development Strategy Area. The target is for the development of 3 hectares of employment land by 2022, with milestones set in between. During the period 2007 - 2012 approximately 8.4 hectares of B1, B2 and B8 commercial floor space equating to 11.7ha gross of employment land has been completed within the Urban Development Strategy Area. This is the baseline figure with the expectation that a further 3 hectares will be developed by 2022. When looking at the 2016 AMR, only an additional c.2,500sqm (0.3ha gross) has been constructed since the adoption of the LDP. This development took place on the North Wales Business Park, Abergele during 2015, and was for a care centre (Sui Generis use class) rather than a B class use.
5.3.4 In addition, recent permissions within the Urban Development Strategy Area include;
- Esgyryn, Narrow Lane, Llandudno Junction - 0.2 hectares (approx. 750 sq. m) of B1 office space creating up to 80 jobs
- Former Brickworks site, Llandudno Junction - permission
granted for 8,700 sq. m retail superstore, petrol filling
station and restaurants (x4 = approx. 1400 sq. m) creating
approx. 250 jobs.
5.3.5 Regarding development in the Rural Strategy Area monitoring indicator MI/027, the target is 3 hectares of development by 2022, with a baseline of 0ha since 2007. Since adoption of the LDP, no commercial development has been completed on allocated sites within the Rural Development Strategy Area, although 1,500sqm of B1 class use at Ty Gwyn, Llanrwst is currently under construction.
(1) 5.3.6 Despite such developments as those mentioned above, the conclusion within the 2016 AMR is that the performance against the monitoring indicators is below what is expected in terms of B1, B2 and B8 use. It is possible that this is reflective of economic conditions generally, but failure to meet the LDP targets suggests that further work is needed to understand if the quantity and location of the supply of employment land is capable of matching current and future demand.
(1) 5.3.7 Policy EMP/3 is a criteria based policy which supports employment development on non-allocated sites where the criteria is fulfilled. The spirit of this policy is in line with new national planning guidance which requires LDPs to incorporate flexibility (para 4.7.1, TAN 23), however criteria within will need to be reviewed to ensure it is in line with other LDP policies that may be subject to change.
5.3.8 Criteria based Policy EMP/4 on safeguarding has been cited on numerous occasions when dealing with planning applications since LDP adoption. Due to changes in national planning policy guidance, EMP/4 will require review. More details on EMP/4 are given in section 5.2.2.
(1) 5.3.9 Office and industrial employment improvement areas are covered under policy EMP/5. There is support for making less environmentally sensitive areas (such as those brownfield sites listed in the policy) more attractive for potential investors rather than pursuing greenfield land, for example (para 2.1.14, TAN 23). However the list of employment sites within will need to be reviewed to ensure it is in line with other LDP policies that may be subject to change.
(1) 5.3.10 EMP/6 deals with re-use and adaptation of redundant rural buildings. National guidance para 3.2 TAN 23 also has criteria which covers this. This policy should therefore be reviewed to ensure it is not repeating or in conflict with national planning policy.
Changes to National Planning Policy Guidance (PPW) Chapter 7 and TAN 23 - November 2014
5.3.11 Since the adoption of the Conwy LDP in October 2013, Planning Policy Wales and TAN 23 - Economic Development have been revised / produced and have implications on the planning decisions made. Planning Policy Wales (PPW) at paragraph 7.5.1 states that Development Plans should:
- provide targets on land provision for the employment uses (Classes B1-B8), showing net change in land / floor space for offices and industry/warehousing separately, and protect these sites from inappropriate development;
- include policies relating to future development on existing employment sites to protect them from inappropriate development:
- to encourage the regeneration and re-use of sites which are still suitable and needed for employment;
- to control and manage the release of unwanted employment sites to other uses;
5.3.12 PPW chapter 7 also advocates the production of Employment Land Reviews (ELRs), and the need to undertake such reviews in line with the published Practice Guidance (August 2015).
5.3.13 Whilst TAN 23 acknowledges that economic activity can stem from the public, private or voluntary sector and include uses beyond the traditional B-class uses such as retail, tourism and leisure; it is held that the aforementioned retail, tourism and leisure uses are subject to a variety of other policies. Consequently the TAN primarily deals with B-class uses given that they require a traditional yet sustainable method of planning. The TAN promotes careful consideration when releasing traditional employment sites to alternative uses as they often make a valid contribution to the local economy and are difficult to replace once lost.
5.3.14 TAN 23 also provides guidance on economic development proposals. Paragraph 4.6.8 states "The traditional employment uses tend to generate lower land values than many other land uses, especially housing and retail, consequently, any land lost to these uses is generally difficult to replace. Planning authorities should avoid releasing for other uses sites where there is strong evidence of likely future need for B1-B8. In some areas, older, lower-cost employment areas may be required, especially for small and new firms who cannot afford newer and more prestigious accommodation. The loss of such areas may cause harm to local economies and should be avoided."
5.3.15 Criteria contained at paragraph 4.6.9 also impacts upon existing LDP policy:
"Existing employment sites should only be released for
other uses if one or more of the following apply:
they have poor prospects of being re-occupied for their previous use;
- the particular market that the site is part of is oversupplied;
- the existing employment use has unacceptable adverse impacts on amenity or the environment;
- the proposed redevelopment does not compromise unduly neighbouring employment sites that are to be retained;
- other priorities, such as housing need, override more narrowly focussed economic considerations; and/or
- land of equal or better quality is made available elsewhere, even if this is not within the local planning authority boundary."
(1) 5.3.16 The changes to national planning policy on economic development mean that some LDP policies, particularly EMP/4 on safeguarding require review to ensure they are in-line with national policy. The need to undertake an Employment Land Review may also mean that an updated evidence base may be at odds with adopted policy and the Economic Strategy.
Population Projections & Housing Growth Strategy
5.3.17 Revised population projections have been released from Welsh Government which will influence the strategy for employment land provision and housing growth. This is detailed within the Strategy section of this Review Report.
Local Economic Strategy
5.3.18 The Conwy Economic Strategy 2017 - 2027 has recently been adopted (February 2017). It considers the initiatives which can be undertaken to enable businesses within the county to grow, diversify, upskill and compete in UK and global markets. It identifies strategic opportunities which would both create new jobs and improve the quality of existing jobs within the local economy, moving from seasonal to year-round employment. It is therefore important that the LDP strategy is broadly in line with the drivers and evidence base contained within this strategy going forward to 2027.
Regional Growth Drivers
(3) 5.3.19 Taking account of new regional considerations the 2016 AMR highlighted the potential land requirement impacts resulting from Wylfa B Nuclear Power Station in terms of the potential for new employment, housing and strategic transport locations. The requirement detailed in the Planning Act 2015 to consider preparing a regional A55 Corridor Strategic Plan will also have an influence. In particular, the North Wales Economic Ambition Board are progressing an Economic Growth Vision that would require statutory support via the LDP, which currently it does not have in various areas. Other regional evidence, such as the Regional Transport Plan will also need to be taken into account during the LDP review.
Emerging Conwy Employment Land Review 2017
5.3.20 In response to all these factors, an Employment Land Review (ELR) for Conwy has commenced and will be a significant evidence base in determining the future direction of the LDP Economic Strategy and future supply, location and type of employment land. The ELR will be fundamental in establishing the regional growth drivers as identified in the last paragraph and their implications on Conwy's employment strategy and the amount of employment land needed up to 2031.
5.4.1 North Wales has been recognised as the fourth best tourism destination in the world by Lonely Planet, and Conwy County is at the heart of that tourism offer. The town of Conwy has an international reputation because of its world class heritage and Llandudno is named as the best seaside town in the UK and the 4th best destination in the UK by TripAdvisor. The county is becoming world renowned as a centre of excellence for adrenaline adventure with Surf Snowdonia, Go Below, and Zip World Forest all leading the way. Major events have attracted new audiences to the county and made significant economic contributions. The key now is to build on that success and to improve the quality of jobs that are linked to this tourism industry.
Planning Policy Wales (9th Edition);
'Tourism is vital to economic prosperity and job creation in many parts of Wales. It is a significant and growing source of employment and investment, based on the country's cultural and environmental diversity. Tourism can be a catalyst for environmental protection, regeneration and improvement in both rural and urban areas.'
5.4.3 WG 'Partnership for Growth 2013 - 2020' strategy identifies a product-led approach to developing and marketing tourism in Wales. This means working with iconic, high quality, reputation-changing products and events. It is unfortunate that whilst tourism is recognised by WG as vital to the Welsh economy the 'Tourism' Technical Advice Note (TAN): 13 released in 1997 remains very much outdated.
5.4.4 Conwy County's 'Economic Growth Strategy 2017 - 2027' aims to make Conwy a truly international, vibrant and year-round tourism destination across all aspects of the visitor experience. There is a need to develop a night-time economy to underpin further growth in the business tourism market which contributes to high visitor spend.
5.4.5 'Destination Conwy Management Plan 2015 -2018' identiﬁes a project-like approach to delivering and marketing tourism in Wales. The Plan focuses on higher quality hotels and facilities with more all year round attractions, activities and cultural experiences that are innovative, unusual and distinctive.
(1) 5.4.6 There are no concerns over the implementation of the strategic objectives. It is considered that the policies are aiding the delivery of the Strategic Objectives in the strengthening and diversification of the rural economy where this it is compatible with local economy, community and environmental interests. They also assist tourism through the protection and enhancement of coastal and rural based tourism attractions and accommodation and further exploit the potential to develop, strengthen and encourage an all year round tourism industry where development complies with other policies in the LDP.
New Sustainable Tourism and Recreational Developments
(1) 5.4.7 Policy TOU/2 'New Sustainable Tourism and Recreational Developments' was formed for large scale tourism developments, especially accommodation additions to recreation sites. It is generally working well and has been used to promote and defend sites which do not comply, however, minor amendments to help clarify the Policy will be required at Review.
Holiday Accommodation Zones
5.4.8 Policies within the Local Development Plan support the improvement of existing serviced accommodation and will support new build tourist accommodation. The Local Development Plan recognises the importance of maintaining a good range of holiday accommodation for visitors.
(1) 5.4.9 The Holiday Accommodation Zone (Policy TOU/3) was somewhat of an inherited situation which was updated and revised according to the latest survey work. However, market influences will have the ultimate control and previously the area has seen a small number of properties wishing to close and be put on the market for various reasons. Lenders also prefer the open market properties to economic ones. However, Conwy is presently experiencing an uplift in tourism related trade and it is important to ensure that the tourism industry demands are being met. CCBC will fully assess this demand as part of the tourism growth strategy in order to provide sufficient, well-informed evidence. An amendment at Review is considered necessary to ensure the need is addressed whilst also allowing for some flexibility in the policy.
Chalet, Caravan and Camping Sites
(2) 5.4.10 Policy TOU/4 'Chalet, Caravan and Camping Sites' is strictly in terms of the coastal areas in only allowing improvements of existing sites and promoting lower densities in preference to environmental or amenity improvements. In the rural area there is some change to the policy needed in order to address the existing large scale static sites from over-developing into sensitive landscapes. There is also a need to improve reference to the growing popularity of the 'alternative camping' (yurts, pods, shepherd huts, etc). An amendment/assessment at Review will be necessary.
Adventure & All year Tourism
5.4.11 Adventure Tourism is a growing market, with new attractions opening within North Wales and existing attractions expanding to cater for this new type of tourism. Welsh Government wish to promote Wales as the world's capital of adventure tourism following 2016's Year of Adventure. Further themes were envisaged for 2017 and 2018 to promote Wales' greatest strengths and focuses activities, events and attractions on the strongest qualities of the Welsh tourism offer. The Welsh Government has invested consistently in adventure tourism products in recent years, many of these attractions are serviced by the facilities and accommodation within Conwy.
5.4.12 The night-time economy and a compelling winter visitor offer are fundamental to establishing Conwy County as a year-round destination. Venue Cymru attracts a wide variety of conferences and business bookings throughout the year. To grow this market, and ensure as many of these bookings as possible are overnight stays, Llandudno needs to offer more things for visitors to do in the evening, including an extended café/restaurant offer. Data shows that visitor numbers across the county dip significantly from November through to February. Investing in attractor events at this time of year and developing attractions which can be enjoyed through the winter period would increase visitor numbers, contributing to the overall tourism economy and creating the environment for more full-time, quality jobs.
5.4.13 As part of the LDP review, and having the Conwy Economic Growth Strategy ambitions and other growth drivers in mind, CCBC will be preparing a tourism growth strategy related to policies/designations for tourism/leisure growth e.g. higher value tourism, all year round in the leisure/activity/adventure sectors, etc.
(1) 5.5.1 PPW chapter 10 and TAN4 were revised in November 2016. Key retailing objectives are similar to previous, but there are some new policy requirements that should be included in LDP policies. These will need reviewing to assess whether the Community Facilities and Services and Development Principles policies provide suitable detail for assessing planning applications. National policy encourages a mix of uses in town centres and suggests that a flexible approach be adopted for change of use. The thresholds identified in LDP monitoring and SPG LDP23 Change of Use in Town and Neighbourhood Centres may need revising to reflect this.
5.5.2 CCBC published a Retail Capacity Study in April 2013. It concluded that there was a need for new retail development in the County Borough to meet demand until 2022:
- Coastal area: 75,000 sq ft convenience floorspace
- Llanrwst: 18,000 sq ft convenience floorspace
- Colwyn Bay: 40-50,000 sq ft comparison floorspace and increase efficiency of current floorspace by 5%, 30-40,000 sq ft comparison floorspace and increase efficiency of current floorspace by 10%, or no additional comparison floorspace and only increase efficiency of current floorspace.
- Llandudno: 15,000 sq ft comparison floorspace and increase efficiency of current floorspace, or no additional comparison floorspace and only increase efficiency of current floorspace.
5.5.3 The comparison floorspace requirement in Llandudno has been met by the TK Maxx application and development in Mostyn Champneys Retail Park. An application for a supermarket proposal in Llandudno Junction has been approved, which meets the majority of the coastal convenience floorspace identified. Progress of developing this site will need to be monitored to ensure that the identified retail need is met. Consideration will be given to designating the wider site to protect its retail and leisure use.
5.5.4 The population figures revised following the 2011 Census and update to population and household projections will impact retail need and demand. These were published after the last Retail Study (2013). Retail habits such as the increase in internet shopping will also need to be allowed for.
5.5.5 An up-to-date retail study will be required to assess changes in retail supply and demand as a result of the updated population base figures and projections, the new Economic Strategy for the region, update to national retail planning policy and changes in shopping patterns. Allocations may be required should a need be found.
5.5.6 The AMR highlighted some concerns in the retail health check indicators (flagged as amber). LDP policies are considered to be operating effectively, but town centre health can be further assessed in an updated Retail Study. Policies may need reviewing to improve vibrancy, viability and attractiveness of the shopping centres. New national policy seeks to secure a mix of uses in secondary retailing areas. The target of non-A1 uses set in the monitoring needs reviewing to reflect this.
(1) 5.5.7 The Open Space Assessment is currently being updated. It assesses the quantity and accessibility of the existing open space sites at settlement level in the Plan Area of the County Borough. It is likely that a shortfall of some open space types will be identified, which impacts on health and wellbeing. Allocations may be required to address this shortfall.
5.5.8 Fields in Trust have published new guidance detailing recommended open space standards for Wales. These vary from previous for some typologies. TAN16 outlines that these standards are the starting point for setting standards in LDPs. LDP policy CFS/11 will need reviewing to reflect this update. In addition, the Council is progressing towards CIL adoption, but a national review in Wales is pending. Major open space provision may be delivered via CIL. CFS/11 may need revising to reflect this.
5.5.9 Monitoring indicates that policy CFS/6 is protecting community facilities as intended. These are vital for rural communities and so minimal changes to the policy are proposed to ensure that facilities continue to be protected. The rural facilities survey will be updated to inform this policy.
5.5.10 Planning permission has been granted for the housing and allotments site in Dwygyfylchi. Work has commenced on construction. The allotments will be delivered as a community garden, which still meets requirements. A financial contribution was sought for viability reasons at Esgyryn, Llandudno Junction.
5.5.11 Fields in Trust have recommended a new standard for delivering allotments and community gardens. Updated evidence base is required to assess whether the remaining allocations meet the identified need, or if further sites are required. CFS/10 needs updating to reflect this.
5.5.12 The sites allocated have not yet been delivered. A review of updated evidence base is required to assess if new allocated sites are required to meet need.
5.5.13 Primary School Modernisation is on-going. One application for a new school in Llandudno Junction has been submitted and approved during the plan period to date. The evidence base and modernisation proposals may result in allocated sites being required. Applications for extending or redeveloping existing school sites may be submitted.
5.5.14 Changes to population structure and new residential development impact on the level of primary care sites and other health care provision required. Evidence base needs reviewing to ensure that service provision can accommodate the change in demand. Allocations may be required to ensure need is met.
Other Community Facilities
5.5.15 Evidence base for other community facilities will be reviewed and updated where required. This includes leisure, youth and libraries.
The Natural Environment
(2) 5.6.1 The LDP's Natural Environment section is broad and includes policies on renewable energy, water and flood risk, air quality and biodiversity, which is general have been well received and utilised. Whilst most the policies are meeting the Annual Monitoring targets there are some significant changes foreseen through the Review process.
5.6.2 CCBC is committed to protecting and preserving its natural heritage and cultural assets for its own value as well as the draw it has on bringing tourists to the area. When adopting the Conwy LDP, the Authority had also prepared joint supplementary planning guidance on Landscape Capacity in terms of wind turbine development Character Areas. This additional guidance has reinforced existing policies and has identified and helped protect the most sensitive and vulnerable landscapes.
Changes to National Planning Policy
5.6.3 Planning Policy Wales was revised in November 2016. The Environment (Wales) Act 2016 sets out the approach to help Wales reduce its carbon emissions. It places a duty on Welsh Ministers to ensure that in 2050 net emissions are at least 80% lower than the baseline set in legislation. This will be achieved through the setting of interim targets for 2020, 2030 and 2040 and 5 yearly carbon budgets up until 2050. Guidance on carbon reduction and LDPs is partly linked to the role and requirements set out in the Renewable Energy Assessments discussed below.
5.6.4 Environment (Wales) Act 2016 also introduces Area Statements in a new approach to landscape mitigation and management within which development will need to be carefully controlled in line with national guidance and any future local designations. The Wales National Marine Plan 2015 is still at initial draft stage but is likely to progress through 2017-18.
5.6.5 Natural environmental objectives and monitoring are continuous, but there are some new policy requirements and legislation that need to be included in LDP policies through the Review. The primary purpose is to protect and enhance the natural environment where new development has an effect. However it is considered that the subject areas need separation to provide clarity to the plan users. TAN 5 "Nature, Conservation and Planning" 2009 has not been updated since publishing.
5.6.6 The Conservation of Habitats and Species Regulations 2010 includes the requirement to carry out a Habitats Regulations Assessment to assess likely impacts. A HRA was carried out for the adopted LDP based on the European Habitats Directive guidance at the time and this will be revised in light of the current Regulations.
5.6.7 The Welsh Government's policy on planning for renewable energy is set out in Planning Policy Wales - edition 9. November 2016 (PPW) and Technical Advice Note (TAN) 8: Renewable Energy. The Welsh Government sent a letter to local planning authorities in 2015 outlining the Minister for Natural Resources' expectations for energy policies in LDPs. A "Practice guidance: Planning for renewable and low carbon energy - a toolkit for planners" was published in 2015 and CCBC have been working alongside consultants to carry out a Renewable Energy Assessment in the Plan area and to introduce polices to ensure RE is integrated from an early stage of the planning process. In particular is the Welsh Government requirement for spatial policies to reflect RE aspirations and its concern that local authorities had not been fully implementing these requirements in their LDPs.
5.6.8 The current adopted LDP was not influenced by the current energy policies in PPW as the requirements were set out just after the LDP was put on deposit. PPW states that local planning authorities should facilitate the development of all forms of renewable and low carbon energy by considering the contribution their area can make and creating LDP policies that enable this contribution to be delivered. It also suggests that development management decisions are consistent with national and international climate change obligations.
5.6.9 Recent changes include a revision to the Renewable Energy Toolkit which was published by the Welsh Government in 2015. The Department of Energy & Climate Change became part of the Department for Business, Energy & Industrial Strategy in July 2016. It now makes decisions on large scale RE projects. National guidance is provided in Energy Wales; A Low Carbon Transition 2012 (updated 2016). It is clear that significant contextual changes have taken place in respect of renewable and low carbon energy since the adoption of the LDP and several changes are foreseen for the LDP.
5.6.10 A revised version of the Renewable Energy Toolkit was published by the Welsh Government in 2015 and Renewable Energy Assessments (REAs) are expected to form part of the Local Development Plan (LDP) evidence base.
5.6.11 The aforementioned letter clarifies that REAs should inform policies, areas of search and allocations which guide local-authority scale (5MW - 25MW) renewable energy schemes or other low carbon technologies to the most appropriate locations. It explains it is imperative that the planning system identifies and protects areas with renewable energy generation potential for the long term.
5.6.12 Policy regarding the control and assessment of wind turbine development is well used however requires amendment through the LDP review process. This issue of defining 'proportionate' and 'predominant energy' could not be overcome as part of the SPG as it changed the essence of the policy. It is clear that significant contextual changes have occurred in respect of renewable and low carbon energy since the adoption of the LDP. This will be a key issue for a revised LDP and policy changes are anticipated.
5.6.13 The Landscape element of the LDP needs amending to reflect the Well-being of Future Generations (Wales) Act 2015, the Environment (Wales) Act 2016 and the Active Travel (Wales) Act 2016. Other national initiatives such as the Woodlands for Wales Action Plan, Agricultural grading of land and peat protection will also influence land use and policy change.
(1) 5.6.14 A Heritage Coast policy would be beneficial as there is a designation without any associated policy. A design and landscape policy would be useful as it needs more than a link to DP6 to promote it and would allow the LPA to seek improved design when challenged with poorly designed schemes.
(1) 5.6.15 The green wedge policy is based on national guidance and is considered robust and consistent in its approach. It is intended to undertake another review of these areas in the future, where some areas may change. This will be undertaken through revisions to the existing Background Paper.
Sustainable Drainage Systems
(1) 5.6.16 The policy with regards to SUDS, Foul Drainage and Water Conservation has not changed since the adoption of the LDP. Therefore is unlikely to require any change. Water Resource Management Plans (WRMPs) need to be taken into account and the Revised LDP will include reference to their requirements. Water companies are required to prepare WRMPs that look ahead 25 years or more and ensure sufficient water supply to the public and maintain adequate water in the environment. The current WRMPs cover the period 2015-2040 for Conwy area and Dŵr Cymru/Welsh Water is the company operating in the Plan area.
5.7 The issues:
5.7.1 The policies continue to perform well in general. Five SPGs (including two Conservation Area Management Plans) have been agreed since the adoption of the LDP which provide applicants and decision makers with further guidance when submitting / assessing applications. One issue of concern is regarding the production and adoption of the remaining Conservation Area Management Plans within a 24 month timescale from the date of LDP adoption, as the deadline for this has now passed. Indeed, since adoption of the LDP, the approach to these SPGs has changed in that an individual SPG for each Conservation Area will now be produced rather than 'generic' Management Plans as first planned. This has led to the prioritisation of Management Plans on the basis of need and existing condition of the Conservation Area in question, with the Conwy and Llandudno Conservation Area Management Plans being adopted in the first instance and Colwyn Bay and Llanelian currently in draft having been out to public consultation. As such, it is felt that LDP monitoring indicator MI/088 is no longer appropriate for this work stream.
5.7.2 The SPG on Listed Buildings was put on hold due to the imminent publication of Welsh Government Practice Guidance on Listed Buildings. This is discussed further under 5.7.3.
Changes to Planning Law - Historic Environment (Wales) Act (2016)
5.7.3 The Historic Environment (Wales) Act 2016 received Royal Assent on the 21st March 2016. The Act forms part of a suite of legislation, policy and advice that makes improvements to the existing systems in place to protect and sustainably manage the historic environment in Wales. Some of the Act's provisions make it harder for those who unlawfully damage a scheduled monument to escape prosecution.
5.7.4 The Act also introduced new structures to support the positive management of change in the historic environment. One of the Act's measures allows owners and the relevant authorities to negotiate agreements for improved management of historic assets over a period of years.
5.7.5 The Act will be complemented by a number of policy and guidance documents that will help to keep the management of the Welsh historic environment in step with current conservation practice. Public consultation has been undertaken on a revised chapter 6 of PPW and a new TAN 24. Other consultations are currently on-going and more are expected during the course of 2017.
Changes to National Planning Policy - Planning Policy Wales (PPW) Chapter 6, TAN 24, Draft Practice Guidance and implications on the LDP
5.7.6 Planning Policy Wales Edition 9 was published in November 2016. The key issues from the revised chapter 6 in PPW for development plans are concerning Historic Environment Records (HERs), Conservation Areas, Listed Buildings, World Heritage Sites, archaeological remains, local historic assets and historic parks and gardens. TAN 24 (published May 2017) and the Practice Guidance documents (still in draft at the time of this report) are also considerations at this point.
5.7.7 With regards to the first of the issues raised in PPW, PPW states that HERs must be used as a key source of information for the formulation of development plans and advice on their use should be sought from the Welsh Archaeological Trusts. When undertaking an SEA and SA, assessment of the cultural heritage (as guided by HERs) is required in consultation with Cadw. PPW also states that 'In undertaking the (sustainability) appraisal, an up-to-date evidence base, including those provided by the HER for the local authority area and the National Monuments Record, must be used.' A review of the LDP will require the above process to ensure all the relevant historic asset data has been considered.
5.7.8 Concerning conservation areas, listed buildings and historic landscapes, parks and gardens, PPW states that development plans should, where appropriate, include locally specific policies for the conservation of the built environment, including the protection or enhancement of listed buildings conservation areas and historic parks and gardens. Given the publication of draft Practice Guidance on Listed Buildings, it is considered that there is no need to replicate this in the form of planning policy and SPG. The same could be said for landscapes, parks and gardens unless the review process identifies Conwy-specific issues.
5.7.9 PPW emphasises that World Heritage Sites have been inscribed by UNESCO because of their Outstanding Universal Value, and development plans must reflect this. New evidence base is emerging in the form of a Management Plan for the Castles and Town Walls of King Edward in Gwynedd World Heritage Site produced by Cadw. This is explored in more detail at 5.6.4 below.
5.7.10 PPW states that archaeological remains and their settings and, in appropriate circumstances, other unscheduled archaeological remains of local importance and their settings, may be identified in development plans as of local importance and worthy of conservation. It goes on to say that local planning authorities may also develop supplementary planning guidance to provide further detail on any locally specific archaeological remains and their settings included as policy in development plans. Consultation with the Archaeological Trusts should identify any unscheduled archaeological remains and whether they merit protection in the LDP.
5.7.11 It is now recognised in PPW the desirability of designating historic assets locally. The LDP already has a policy (CTH/3) and accompanying SPG in place regarding this. It is expected that this policy and SPG will be retained, but the SPG may benefit from review in order to streamline the process of local listing.
5.7.12 Paragraph 6.5.30 of PPW sets out criteria for granting schemes of enabling development. The LDP currently has a policy on Enabling Development (CTH/4) and accompanying SPG. These will need to be reviewed to ensure they are in line with national guidance whilst not repeating such guidance.
World Heritage Site Management Plans
5.7.13 A consultation on a new Management Plan for the Castles and Town Walls of King Edward in Gwynedd World Heritage Site was recently published by Cadw. The recommendations within the action plan put the onus on local planning authorities to work together to produce joint SPG based on the content of the WHS Management Plan. The LDP will therefore need to address the recommendations in this Management Plan and provide mechanisms for the adoption of policy and SPG.
Welsh language - Policy/Legislative Changes
5.7.14 Since Examination of the Conwy LDP, the national planning policy context in relation to the Welsh Language has changed, with publication of the new TAN20 (October 2013) and a revised PPW. PPW para 2.4.4 Fig 4.1, section 4.13, para 9.2.2, 9.2.9 In addition, the Planning (Wales) Act 2015 and Wellbeing of Future Generations Act (2015) give weight to the need to consider the Welsh language through plan preparation and development management.
5.7.15 A new draft TAN20 has been consulted on, which will be updated as a consequence of legislative changes. The LDP review will take account of all new and emerging guidance.
Welsh language - implications for LDP Review
(1) 5.7.16 The LDP Review will need to incorporate a more detailed Welsh Language Impact Assessment than that undertaken prior to adoption of the present Plan. This is to align the policies with the requirements of PPW and TAN20 to front-load this work and avoid the need for impact assessments to be submitted with planning applications in all but a limited number of cases.
5.7.17 Policy CTH/5 and the LDP proposals maps will need to be amended to reflect changes to national guidance and to take account of the results from the new strategic Welsh Language Impact Assessment, when completed. This may include identifying language sensitive areas; significant applications within these areas for developments not anticipated as part of the adopted replacement LDP would be subject to Welsh language impact assessment.
5.8.1 Key changes include the Well-being and Future Generations (Wales) Act 2015, National Development Framework for Wales (2017), Walking and Cycling Action Plan for Wales (2009-2013) and Active Travel (Wales) Act 2013.
5.8.2 PPW was also revised in November 2016. The Growth Vision and Strategy for the economy of North Wales (2016) and Conwy Corporate Plan have also been introduced. Key sustainable transport objectives are similar to previous, but there are some new policy requirements and legislation that need to be included in LDP policies.
5.8.3 Conwy Regional Transport Plan, in part, informed the preparation of the adopted LDP and the North Wales Joint Transport Plan (NWJTP) is also being reviewed which will determine some aspects of the LDP review. Projects that are linked to development within the LDP or otherwise considered as deliverable within the Plan period will also be included.
5.8.4 The priority transport schemes identified in the NWJTP are not fully reflected in the LDP and as such, further consideration needs to be given to the policy and land use implications of such schemes in order to ensure that they are deliverable in the context of local policy.
Active Travel Plan
5.8.6 Active Travel (Wales) Act 2013 became law in Wales on 4th November 2013, making it a legal requirement for local authorities in Wales to continuously improve facilities and routes for walkers and cyclists (non-motorized users) in settlements with a population of 2,000 or more within a built up area. It will be necessary to formulate land use policy to support, protect and enhance the elements identified in the Conwy ATP and its Integrated Network Mapping (INM) within the LDP.
Minerals and Waste
5.9 The issues:
(1) 5.9.1 Overall, considering the changes to national planning policy for waste management since adoption of the LDP, the strategic policy (currently MWS/1) is lacking in that it does not make reference to the principles of the waste hierarchy, and this needs to be addressed. The policy would also benefit from having more focus in terms of where new waste facilities should be directed. Another element which requires further elaboration is around reducing the production of waste and managing waste recycling. PPW (para 12.6.3) and TAN 21 require LDPs to seek opportunities to reduce, recycle and store waste at the design stage of development. At the moment there is a link from Policy DP/1 to MWS/1 but it is considered that the policy in the Minerals and Waste chapter could go further to address this and provide a further policy basis for the adopted SPG on Waste Storage and Collection in New Developments.
(1) 5.9.2 Regarding minerals, The Regional Technical Statement 1st Review (2014) includes a number of recommendations for each local authority which in some cases differ to those contained within the 2009 Regional Technical Statement (the evidence base used when producing the LDP.) However, the advice for Conwy remains largely the same given the extensive hard rock reserves which remain, and the distribution of sand and gravel. Therefore policies MWS/2, MWS/3 and MWS/4 are still relevant in that they reflect the most up to date evidence base, although they may benefit from SPG.
5.9.3 The Conwy Local Development Plan was written in the context of the Regional Waste Plan 1st Review and both policies MWS/5 and MWS/6 and the monitoring indicator and trigger levels were established using the capacity requirements contained within the RWP 1st Review. The capacity calculations contained within the Region Waste Plan (RWP) 1st Review are now out of date and have been superseded by national policy. National policy now requires LPAs to consider waste as part of an employment land review.
5.9.4 Policy MWS/5 includes a test that requires proposals to demonstrate they meet a need identified within the Regional Waste Plan or a need arising at the local level. Since the requirement to produce and have regard to the Regional Waste Plans have been removed from national policy and guidance, the strict application of this test could result in the approval of proposals that are contrary to national policy and/or guidance. The revised national policy and guidance seeks to avoid overprovision of certain facility types, i.e. disposal and recovery. Therefore within the updated guidance 'need' in relation to other facility types only becomes relevant where a proposal is outside an allocated site, and is more likely to be related to local need. It is recommended that this policy is amended during the review of the LDP to enable this inconsistency to be addressed and to ensure that the 'need' test is applied in line with TAN 21. MWS/5 will therefore need to be reviewed and updated in line with current evidence base to ensure that any emerging requirements can be met through the LDP.
(1) 5.9.5 Although national policy and guidance has changed with respect to waste management, policies MWS/6 and MWS/7 have so far been considered sufficiently flexible to enable waste infrastructure to be delivered. However, given the slow take-up of allocated sites and potential problems in terms of delivery, it may be necessary to undertake a call for new sites / consider a quota of land as part of the call for employment sites during the Employment Land Review. There is also a need as identified within TAN 21 for LDPs to specifically allocate 'urban quarry' sites for the storage of inert wastes.
5.9.6 Regarding landfill, capacity exists at the regional level and it is anticipated that due to increases in recycling rates, this will be the case during the lifetime of the LDP. TAN 21 identifies a 7 year trigger (the level at which void capacity should be maintained) and a 5 year trigger (the point at which action would need to be taken to facilitate future landfill provision). The regional monitoring identifies whether either of these triggers has been met and to date this identifies that the void within the region is well above both of these triggers. Therefore there is no need to undertake a landfill study site search / allocate additional landfill capacity at this time, although the situation will need to be kept under review.
(1) 5.9.7 Policy MWS/8 is still relevant in that it applies to the landfill site at Llanddulas. It has been queried if some of the wording in the supplementary text should be added to the policy itself. This will be addressed at the review.
Changes to National Planning Policy Guidance (PPW) Chapters 12 (February 2014) Chapter 14 (January 2016) and TAN 21(February 2014)
5.9.8 Since the Local Development Plan was adopted, the Welsh Government has updated Planning Policy Wales which contains a revised section on waste at Chapter 12. The Welsh Government has also published a revised TAN 21 which removed the requirement to produce Regional Waste Plans and the need for development plans to have regard to the relevant Regional Waste Plan.
5.9.9 TAN 21 includes a regional requirement for monitoring which will monitor progress and level of need. These monitoring arrangements to be established with the aim of publishing an annual Waste Planning Monitoring Report, which would set out an up to date position with respect to need for disposal and recovery capacity. An interim Regional Waste Monitoring report (2013/14) has been produced for North Wales and a draft RWM report produced (2014/15). The findings of the interim report were that there is no additional requirement for disposal capacity within the region as reflected above in terms of landfill need, and the conclusion contained within the Interim RWM report and the draft RWM report is that any proposals for further residual waste treatment should be carefully assessed to ensure that the facility would not result in overprovision.
5.9.10 In order to establish monitoring indicators and triggers which would be appropriate, the requirements of TAN 21 are considered below. TAN 21 requires Local Development Plans to ascertain whether:
- Support for any local authority procurement programmes is necessary;
- Any agreement contained within the Regional Waste Monitoring Report needs to be addressed by way of a site allocation; and
- Whether any opportunities exist to derive benefits from facilitating co-location and the development of heat networks.
5.9.11 In terms of a) during development of the LDP consideration was given to any spatial requirements of the local authority procurement programmes, namely the North East Wales Hub Food Waste Project, a collaboration between Denbighshire, Flintshire and Conwy to procure food waste treatment and the North Wales Residual Waste Treatment Partnership Project, a collaboration between Denbighshire, Flintshire, Conwy, Gwynedd and Anglesey to procure residual waste treatment. No spatial requirements were identified within Conwy for either the North East Wales Hub Food Waste Project or the North Wales Residual Waste Partnership Project. This matter should however be kept under review, particularly as supporting infrastructure requirements may change. Consultation with the Waste Manager is recommended to ascertain local need and if this can be factored into the LDP review.
5.9.12 Regarding point b) the Interim Regional Waste Monitoring Report and Draft Regional Waste Monitoring (RWM) Report both conclude that there is no further need for disposal capacity within the North Wales region and any proposals for further residual waste treatment capacity should be carefully assessed to ensure that the facility would not result in overprovision. However, this matter should be kept under review.
5.9.13 When considering point c) the North Wales Residual Waste Partnership project has not identified any spatial requirement for Conwy and secured planning permission for a facility on the Deeside Industrial Estate, a location which also offers potential opportunities for the development of heat networks. There is a fine balance to be met between having sufficient capacity to manage residual waste arisings and having an overprovision, which the Collections, Infrastructure and Markets Sector Plan cautions against. Proposals for such facilities would therefore need to be rigorously tested to ensure that they would meet a required need and not result in overprovision of recovery. So, whilst it is important to recognise the potential opportunities that may exist within the County Borough, it is considered unnecessary to include a specific allocation at this moment in time.
5.9.14 With respect to monitoring, TAN 21 (para 3.22) recommends that take up of sites by waste management uses should be monitored as part of the AMR process. Other aspects such as need for recovery and disposal sites should also be considered as a future review of policy would be prompted by the significant contextual change demonstrated within the Waste Planning Monitoring Report.